David C. Jonson and Estate of Barbara J. Jonson, Deceased - Page 31

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                    2.  Discussion                                                    
               As directed by section 6015(f), respondent has prescribed              
          procedures to use in determining whether a relief-seeking spouse            
          qualifies for relief under section 6015(f).  Those procedures are           
          found in Rev. Proc. 2000-15 (the revenue procedure), 2000-5                 
          I.R.B. 447, modifying and superseding Notice 98-61, 1998-51                 
          I.R.B. 13.  Section 7 of the revenue procedure states that it is            
          effective on January 18, 2000, which precedes David’s submission            
          to respondent of the Form 8857 on June 13, 2000.  Section 4.03 of           
          the revenue procedure, applicable to a relief-seeking spouse in             
          Barbara’s situation, provides:  “The Secretary may grant                    
          equitable relief under � 6015(f) * * *  if, taking into account             
          all the facts and circumstances, it is inequitable to hold the              
          requesting spouse liable for all or part of the unpaid liability            
          or deficiency.”  The revenue procedure includes a partial list of           
          positive and negative factors that will be taken into account in            
          determining whether to grant full or partial relief and cautions            
          that no single factor will be determinative of whether equitable            
          relief will or will not be granted in any particular case.  It              
          states:  “Rather, all factors will be considered and weighed                
               Petitioners have failed to introduce any evidence showing              
          the basis for respondent’s rejection of their claim for equitable           
          relief for Barbara.  Nevertheless, the revenue procedure                    
          establishes as factors weighing against equitable relief whether            

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